View the feedback we have received on the NTC Consultation RIS - Barriers to the safe use of personal mobility devices paper.
- Question 1: Are the requirements in the proposed regulatory framework appropriate? Are there any requirements that should be removed, included or modified? Please provide a rationale to support your position
I think the proposed use and speed limits for use of PMD's make the most sense in allowing people to use these devices to travel efficiently, reduce their carbon footprint, reduce road congestion, allow safe shared use of public areas yet still allow PMD's to be able to cover the 'last mile' quick enough to be viable. Its a very sensible proposition that all people wishing to use PMD's in their correct context will embrace.
- Question 2: Is 60kg a suitable maximum weight for a PMD? If not, what is a more suitable weight and what other factors should be considered? Please provide a rationale to support your position.
I feel that the actual weight limit should be even lower, certainly at this stage. The 2 things that weigh the most on PMD's are the battery and motor, the 2 things that also allow sharp increase in speeds. If you limit the weight, you limit the ability to naturally build faster PMD's, you also reduce the inertia of the vehicle in regards to an accident, and also by reducing weight you, typically, increase it's manoeuvrability. My suggestion, depending of course what PMD's are ultimately covered by this law, would be half the recommended weight, so 30kg's. I feel there will also need to be rules about maximum weight of PMD's that can be carried on public transport, and I'd set this to 20kgs.
- Question 3: Should children under the age of 16 years old continue to be permitted to use a motorised scooter incapable of travelling more than 10km/h on level ground on roads and paths? Or should they be able to use any device that complies with the proposed PMD framework? (see Appendix A). Please provide a rationale to support your position
This is an interesting one. I feel that the 10kph limit is still correct and fair. I don't feel that there is valid reason for anyone under a certain age to need to go faster. The only counter point to that, is there are no (tangible) limits to how fast kids can go on bikes, and yet, working in the media, I don't see a large amount of child deaths from bicycles. Perhaps a change to lower the age, to maybe 14? I know that my boys, 15 and 16, live 4.5km's from school, with cycle ways the entire length, to me, they would be perfect candidates for using an Electric Scooter to get to school.
- Question 4: Do you agree with the criteria selected to assess the options? Are there any key impacts not covered by these criteria?
I agree with the criteria at this stage. I feel with time, that the use of PMD's would instead shape our approach to personal mobility lanes rather than the other way around, which would be a great outcome.
- Question 5: When considering the safety risk assessment, access and amenity impacts, broader economic impacts, as well as compliance and enforcement impacts; has the impact analysis sufficiently considered all relevant variables and available evidence? What other factors could be included in the analysis? Please provide any additional evidence. (See Appendix E - Impact Analysis
A consideration has to be made to what is allowed on buses and trains, as this will become more common. There will be a need for these to be carried on buses or trains, otherwise there is no point. however I'n not sure the size and weight, as outlined in the proposal, is practical. I would limit PMD's to a maximum weight of 20kg (so the ability to be, generally, carried in one hand) and also not take up physical seating in buses or trains. Most electric scooters on the market, that will best meet the speed criteria as outlined in the proposal, will fold up small enough to not be a burden on public transport.
- Question 6: What do you believe is the most appropriate road infrastructure for PMDs to access: footpaths, separated paths, bicycle paths and/or roads? Please provide a rationale to support your position
I feel that the rules governing standard kick scooters are a very good starting point. I have a standard kick scooter at the moment and my speeds are only about 10% down on what I would achieve on an electric scooter limited to 25kph. I think cycle lanes and shared cycle/walking lanes are a given, roads of 50kph, and shared pedestrian paths at 10kph are a perfect balance and should allow most users to get to where they need to go. Bear in mind too, that the legalising of these PMD's would lead to a bigger push for more cycle lanes, a win for all commuters.
- Question 7: What is an appropriate and safe maximum speed that PMDs should be permitted to travel across the various infrastructure: (a) pedestrian areas, (b) bicycle areas, and (c) roads? Please provide a rationale to support your position
Roads and dedicated cycle ways I would like to see 30kph, an average cyclist can comfortable cycle along at this speed and ultimately PMD's should aim to co exist with cyclists with as little impact as possible. having said that I totally understand why a compromise of 25kph has been selected. Pedestrian paths, again, I'd like to see 12kph but I feel that 10kph is fair. Every electric scooter I have seen has the ability to set a pedestrian mode (speed limiter)
- Question 8: Do you agree with the overall assessment that Option 3, Speed Approach 1 is the option that best balances mobility and safety? If not, which option and speed approach do you prefer? Please provide a rationale to support your positio
Yes, 100% we want to keep people safe, yet embrace this technology, the time has come, we can lower our carbon footprint, reduce vehicles on the roads, make better use of the public transport system..... My last suggestion? Have as many people as possible who are involved in framing and approving this proposal actually try the PMD's for themselves, let them see how easy/hard they are to ride and manoeuvre, how well they server their purpose, it may be a real eye opening experience.